CCA Baseline Review for an Energy-Intensive Dairy Processing Site
Why product mix and operational change matter more than you think
Is your site’s Climate Change Agreement (CCA) performance deteriorating on paper… even when your plant is running as efficiently as ever?
Across multiple energy-intensive sectors, we are seeing sites whose 2022 baselines remain technically valid but no longer reflect current operational reality. Changes in product mix, throughput, or process configuration can materially alter energy intensity, even when underlying efficiency remains stable or improves.
Why simple energy-per-tonne metrics can mislead
Many CCA targets are built around a total energy vs total production metric. This works well where output is homogenous.
However, over time sites evolve the following can occur:
- Movement between higher- and lower-energy-intensity product streams
- Variation in thermal or cooling loads driven by product specification
- Additional processing stages or quality treatments
- Automation upgrades altering electrical baseload
- Electrification of heat or fuel switching
When production changes occur, energy intensity changes too.
If this isn’t understood and evidenced correctly, performance projections for Target Period 7 (TP7) and beyond can appear misaligned: not because of inefficiency, but because structural drivers have changed.
Our approach: reviewing baseline representativeness
Bellrock's Energy Team undertook a comprehensive technical and regulatory review, combining:
- Processing mapping
- Energy intensity analysis
- Baseline representativeness assessment
- CCA Operations Manual interpretation
- Audit-readiness validation
Our focus is on ensuring your baseline remains robust, defensible and reflective of current operations.
Validate the installation and associated evidence pack
A defensible baseline starts with boundary clarity. This includes:
- Confirming the eligible installation boundary aligns with permits and the CCA Operations Manual
- Reviewing Directly Associated Activity (DAA) definitions
- Updating process flow diagrams and site plans to reflect current configuration
- Verifying that metering architecture, data flows and 70/30 calculations consistently demonstrate ongoing eligibility under the CCA scheme
Analyse production drivers and energy intensity
We review:
- How product or process mix has shifted since the baseline year
- Which processes drive thermal vs. electrical demand
- The proportion of fixed vs variable energy consumption
- Whether throughput assumptions remain representative
This ensures forward projections are grounded in operational reality rather than historic averages.
Future-proof for 2026 and beyond (TP7–TP9)
With the transition into the new CCA period, sites should ask:
- Does our CCA baseline still reflect our core eligible processes?
- Have operational or process changes altered the energy profile since the baseline year?
- Is our evidence pack clear enough to explain material shifts in performance drivers?
- Are we positioned fairly for the 2026 target milestone?
A proactive review reduces audit risk and improves confidence in future target performance.
The bigger picture
Climate Change Agreements are designed to reward efficiency improvements… not penalise commercial evolution.
Where product mix, process configuration or energy drivers have shifted, sites should ensure their evidence packs and baseline assumptions remain aligned with operational reality.
The earlier this is reviewed, the stronger your position.
If you are worried about CCA3 compliance or performance, a structured baseline and evidence review can provide clarity before compliance risk materialises.
